Data protection (DPIA summary)

Beta. These pages have not been reviewed by counsel yet. No data protection officer is appointed for the free beta; write to privacy@lotusmind.one.

This is a public summary of the draft data protection impact assessment for The Still Hour. The DPIA is not signed yet; it awaits the controller's signature. No lawyer has reviewed it. The open counsel items OC-1 to OC-8 were answered by an AI review with three different models; that review is not legal advice. No data protection officer is appointed for the free beta. Controller: Lotus Mind Limited, company no. 826314, 10 Aderrig Manor, Adamstown, Lucan, Dublin K78 A4T8, Ireland, privacy@lotusmind.one.

Why a DPIA

Choosing a tradition can reveal religion or belief (GDPR Art. 9). The design therefore avoids linking a tradition to a person, and asks for explicit consent before any tradition is sent to a model provider.

Measures in the build

• The session start call carries only the 18+ confirmation. No tradition is sent or stored at that point.
• Sacred-text files are addressed by an opaque SHA-256 prefix (/c/v1/r/<sha256-16>.json), so no request path names a tradition or a language in plain words. The site also publishes an index (/c/v1/index.json) that maps each hash to its tradition, so a recorded request path can be resolved back to a tradition by anyone who has the index. The protection is that this host writes no request log, not that the hash is a secret.
• The open-session limit uses a signed first-party cookie and an in-memory salted hash of the network address with a daily rotating salt. Neither is logged. The address is read from the rightmost proxy hop only, so a visitor cannot use a forged header to spend someone else's allowance. People who share one network address (a household, an office or a mobile carrier) share one allowance of 12 session starts per hour.
• The Night Folio is stored only in your browser.
• No third-party requests: no analytics, fonts, CDN or advertising.
• No geolocation API. You choose the place; the browser's time-zone name is read on your device only.
• Gloop carries a tradition and reference only when a verified member ticks consent and presses Ask; the answer log stores the model leg, not text; a server-side check blocks answers that reproduce long sacred passages or issue rulings.
• Login uses a one-time state value and a short-lived assertion signed by the Hub; this site holds no Hub password or user database.

Open points

• Counsel sign-off on the server-side open-session counter and on the cookie classification (see Cookies).
• Gloop is on for verified members and runs only on a model run by Lotus Mind (GLM-5.3-Flash), reached over our private network. No third-party model provider is used: the server refuses to start if one is configured, and when our model is busy or down Gloop answers "Gloop is busy, try again in a moment. Your question was not sent anywhere else." instead of sending your question elsewhere. Turning on any third-party model reopens this assessment.
• Public content files are addressable at hashed URLs, and the public index maps every hash to its tradition; the 18+ confirmation does not hide those bytes. The map stays public by design: the browser must find the right file without sending the tradition to the server (no tradition is ever sent or stored), and any lookup a browser can do is readable by anyone.
• Retention: free cookie 90 days, member cookie 12 hours, rate-limit hash counted per hour and linkable to an address only until the salt is replaced on the first request after 00:00 UTC, no request logs, no server store (see Privacy §5).

Controller: Lotus Mind Limited, company no. 826314, 10 Aderrig Manor, Adamstown, Lucan, Dublin K78 A4T8, Ireland · privacy@lotusmind.one · Complaints: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland — dataprotection.ie, 01 765 0100 / 1800 437 737.

Version lm-pray-dpia-20261111-v1 (beta). Translations of these pages were drafted by AI and checked only by AI reviewers, on the owner's decision; they are not legal advice and were not reviewed by counsel or a native speaker.